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SBN and or panel will be breaking the law by holding a hearing tomorrow in violation of scr 105(2)(c) proof attached From: Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 Zach has a file to share on skydrive.
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11 13 12 and 11 14 12 Emails to Sbn and Panel 0204
SBN and or panel will be breaking the law by holding a hearing tomorrow in violation of scr 105(2)(c) proof attached From: Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 Zach has a file to share on skydrive.
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SBN and or panel will be breaking the law by holding a hearing tomorrow in violation of scr 105(2)(c) proof attached From: Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 Zach has a file to share on skydrive.
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Attribution Non-Commercial (BY-NC)
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Скачайте в формате PDF, TXT или читайте онлайн в Scribd
SBN and or Panel will be breaking the law by holding a hearing
tomorrow in violation of SCR 105(2)(c) proof attached From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Tue 11/13/12 3:22 PM To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); rosec@nvbar.org (rosec@nvbar.org) You will be criminals as of tomorrow if you hold that hearing. SCR 105(2)(c), SBN"s Index for Hearing is holding out certificates of mailing and or proofs of service on the most materials documents incident to a due process analysis (10 9 12 Notice of Intent to Take Default was recieved as returned due to insufficient postage by the SBN on 11 8 12, I declare under penalty of perjury...nrs 53.045...further, SBN only sent one envelope of that document, that returned for insufficient postage certified mail mailing on 10 9 12. Additionally, SBN is holding out 10 12 2012 certified mailing of Notice of Hearing and Designation of Witnesses and Summary of Evidence as having a date of 10/12/12 for a constructive notice analysis, despite the USPS proof indicating the first scan in a USPS system occurred on 10/16/12. Additionaly, the SBN and Peters formally declared that the 8/23/12 mailing was returned to the SBN and that another certified mailing of the Complaint would immediately be sent out, and that the 8/23/12 certified mailing would never be offered to prove proof of service under SCR 109 or in any other manner offered as proof of service of the Complaint. Yet that is just what King has done by his Index putting that forward. Sincerely, Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com Zach has a file to share with you on SkyDrive. To view it, click the link below. 11 13 14 attachment proving 0204 sbn and panel fraud scr 105(2)(c).pdf From: zachcoughlin@hotmail.com To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com Subject: FW: Date: Sun, 11 Nov 2012 07:50:13 -0800 Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR 116 appeal rights... Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN Laura Peters signed a waiver of service or similar and the 10 31 12 Pre Hearing Motion to Dismiss Summary J udgment/Memorandum of Law (Response)
Date: Mon, 13 Aug 2012 11:28:12 -0700 From: silverman@silverman-decaria.com To: zachcoughlin@hotmail.com Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7) I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final judgment in the crim case and point out that your temporary suspension is akin to a permanent death of your practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now have access to your meds and are ok. I can't think this pleading is going to help you much...it is too long, repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't make your case in 3-5 pp, you can't make your case in 35. You do seem to be a good lawyer, however. At bottom, Steve Harris took hundreds of thousands of dollars and had no temp suspension; you stole a candy bar (at worst). WTF. Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com
City Attorney Skau, updated discovery in iPhone case, dispatch recordings, don't seem to reveal basis for "a possible fight" assertions in office testimony and prosecutors's filings and argument From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Wed 11/14/12 2:09 AM To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); rhrc@laketahoelaw.com (consult@laketahoelaw.com); stuttle@washoecounty.us (stuttle@washoecounty.us); kadlicj@reno.gov (kadlicj@reno.gov); wongd@reno.gov (wongd@reno.gov); schornsby@nvdetr.org (schornsby@nvdetr.org); jleslie@washoecounty.us (jleslie@washoecounty.us); jgoodnight@washoecounty.us (jgoodnight@washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us) Dear DDA Young and Bar Counsel and Panel Members, The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is what started all this off (by "all this" I mean the 46 days in jail, the 10 different trips to jail, the five to six different evictions, all summary, the competency evaluations, and all the associated grievances. This arrest and prosecution have largely been based on and the office and prosecutor have cited to, their contention that the information from ECOMM or dispatch told the RPD Officers (and the arresting Officer Nick Duralde is married to a dispatcher working that night and perhaps whose voice is on these files, finally given to me only today, by Reno City Attorney's Office Creighton Skau, after he secured my attendance at a hearing that I do not believe was noticed in a legal since by sending me an email saying J udge Sferrazza authorized service of the notice of the hearing by email...which J udge Sferrazza denies (in fairness to Mr. Skau...its possible the J udge did say that...Mr. Young could maybe shed some light on that, as apparently their was a sort of group meeting with he, the Reno City Attorney and the WCPD on or about November 8th, 2012 in rCR2012-063342, that I was not noticed on and, of course did not attend). Anyways, DDA Young and Officer Duralde have constantly harped on how dispatch reported a "possible fight" and how that somehow justified the rash approach taken by Officer Duralde, the overcharging of "oooh, that's a felony" Felony Grand Larceny (7 days in jail, the eviction notice in the Richard Hills summary eviction from my former home law office was served during the interim in RJ C Rev2011-001708) for a three year old iphone that the alleged owner, Cory Goble, testified was worth about $80 at the time....(and the overcharging of a felony enabled Officer Duralde to conduct a search incident to arrest for a misdemeanor not committed in his presence, after 7 pm...which Nevada law prohibits, particularly where, as here, there was no citizen's arrest (Coughlin himself called 911 and there is a video of the time prior to arrest where Coughlin is heard imploring the skater youths to stay peaceful and wait for law enforcement to arrive so a civil resolution of the dispute could be garnered). I am writing now and providing this new production of ECOMM/911 dispatch recordings that would seem to be the State's last hope of proving that the Officers were told of, by dispatch, "a possible fight" and therein provide some factual basis for that which Officer Duralde and DDA Young have testified to, and filed pleadings in that matter arguing that reports of "a possible fight" justified the subsequent terry stop weapons check pat down, and search incident to arrest (remember, Officer Duralde announced 20 seconds into arriving on scene that he was going to arrest Coughlin and do a search of Coughlin's pockets prior to conducting any of the pretexutal "investigation" that he later testified to...its just that Officer Duralde did not realize he was being recorded when he said that....no matter how he "remixed" things in his Supplementary Declaration (filed within 48 hours of arrest) or his Narrative (by all indications, the Narrative was only filed some three months after the arrest and apparently after the RPD and City Attorneys Office became aware that the video of the arrest was publicly available). I have listened closely to these dispatch recordings and hear nothing about "a possible fight". Does that make the Officer's Testimony perjury and DDA Young's conduct misconduct? DDA Young, I have a Hearing in a few hours on 11/14/12 at the SBN's Office on Double R. Blvd. I ask that you attend and explain these matters as this arrest is pled in Bar Counsel Kings SCR 105 Complaint. Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure to subpoena the dispatch recordings until October 3, 2012 (despite the Trial occuring on May 7th, 2012 (in violation of NRS 178.405, no less), and again on J uly 16th, 2012....and, again on August 29th, and September 5th, 2012....and then please explain why you feigned inability to personally serve subpoenas as a basis for failing to get Nicole Watson (easily found and or served via a certified mailing under NRS 174.345, at the addresses your investigator refused to turn over to me until November 2012 upon a court order (you guys are supposed to help defend the accused, not the County or local law enforcement against their potential civil liability for ego driven foolish arrests) as a student at McQueen High School along with Lucy Byington, both percipient witnesses, and where Watson was captured on tape admitting to the "man with a six-pack" holding the phone aloft and offering it up, and announcing, very loudly, that he woud "throw it in the river" if it was not immediately claimed (therein presenting yet another claim of right defense and further vitiating the legitimacy of DDA Young's retaliatory, deficiently pled, amending of the Complaint on December 5th, 2012 to included "possessing or receiving stolen property from another". I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein the City Attorney's gained an advantage and prejudiced my ability to defend in both NG12- 0204, etc. (the Bar Hearing) and the petty larceny Trial (in RCR2011-063341). I will note that at least J oe Goodnight gathered the three 911 calls. Sincerely, Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com Zach has 66 files to share with you on SkyDrive. To view them, click the links below. PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-45 PM Source_ID = 44.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 1.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-49 PM Source_ID = 31.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-00 PM Source_ID = 36.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-06 PM Source_ID = 38.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13.wav new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest in SCR 105 Complaint PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21.wav Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17.wav PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.wav PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav Download all
From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Wed 11/14/12 6:46 AM To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com); (nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org); (fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com); (eifert.nta@att.net) (eifert.nta@att.net); (consult@laketahoelaw.com) (rhrc@laketahoelaw.com); (stuttle@washoecounty.us) (stuttle@washoecounty.us); (kadlicj@reno.gov) (kadlicj@reno.gov); (wongd@reno.gov) (wongd@reno.gov); (schornsby@nvdetr.org) (schornsby@nvdetr.org) Dear Panel and Bar Counsel, Please find the attach additional discovery the Reno City Attorney's Office gave me today related to the custodial jaywalking arrest of 1/12/12, at which time Richard Hill applied for an received a TPO from RJ C J udge Schroeder in 40 minutes (and RPD Officer Look took a special trip to the jail to attempt to serve the TPO for Hill). Please see attached the video of the arrest and interactions prior thereto, and consider the lack of accuracy in Hill and Baker's Second Motion to Show Cause, J udge Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause Hearing (which WCSO Deputy Machen, the same one who filed a false affidavit incident to the summary eviction order posting and lockout on 11/1/11 in the Richard Hill eviction cases rev2011-001708 served on Coughlin, by way of violating the "courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that case Coughlin did not require personal service anyways...this was hazing by Hill and the RMC Marshals and WCSO Deputies, plain and simple, at the 2/27/12 Trial in 11 TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD Sargent Tarter telling Coughlin to leave Hill's office upon going there after being released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12 resulting in a wrongful arrest for criminal trespass of Coughlin by RPD Officer Chris Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer Hollingsworth in seeking to abuse process and have Coughlin arrested. Then trainee Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for "misuse of 911" which DDA Young nows seeks to amend to a crime that will leverage the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable cause basis for doing so. Further, both Hill and Officer Leedy substantially misrepresent what Officer Hollingsworth said. Additionally, should Officer Hollingsworth had indeed told Coughlin that what he was doing was legal but that the Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve cooperation, that would violate Soldal v. Cook County, which is essentially what RPD Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which les to 11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes a lot of people to help Board member Richard G. Hill, Esq. and his fled-to-Kentucky associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half- way believing RPD Officer Carter's statement on 11/15/11 that "Richard G. Hill pays me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's merely attributing the statement that RPD Carter said to Carter is not misconduct. Hill's making up things about a "crack pipe and bag of weed" and "large quantity of pills" (see the video "Zach's arrest 014 that Hill and Merliss themselves filmed to see that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that mentions this "large quantity of pills"). If you knew all the Thursday nights I spent since 2003 with Coe, and now deceased J udge Bob, and so many others, you would realize how infinitely tacky Hill's conduct is. Sincerely, Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com Zach has 14 files to share with you on SkyDrive. To view them, click the links below. 1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda 7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204 25 page discovery northwind ncs krebs reduced size.pdf 1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012- 000018 0204 Leed.pdf SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4 SAM_0189_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4 rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf 1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf 4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf 11 9 12 61901 amendment to opposition.pdf 11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder ptthoa 0204.pdf 10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf bifurcate atty client severe hearing trialotjl.pdf bifurcate atty client severe hearing trial.pdf CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800 NG12-0204 BF.pdf Download all
12 24 12 0204 Challenge for Cause and Disqualify Refaxed to Sbn With Corrected Caption Notice of Appearance and 11 15 12 61383 Chalenge for Cause and Motion to Recuse Echeverria and Kent Etc Reconsider Bifurc (2)
10 31 13 72675 65630 63341 71437 607 599 Filing and Voxox Fax Proof With 4 4 13 Fax Header's Motion To Strike Remand and Sentencing Memor and Extension of Time Sought Appt of Counsel Etc. Vacate Epo
08-12-09 Samaan v Zernik (SC087400) Countrywide's in-house counsel Todd Boock's refusal to respond - December 2008 to March 2009 - and prevent courtroom fraud based on false banking records produced by Countrywide in response to legal subpoena of records
10 31 13 72675 Motion To Strike Sentencing and Remand Etc Plus Voxox Proof of Service Fax On WCDA Z Young and Stege 65630 63341 71437 72675 and Wastts in 599 607
10 24 13 72675 Printed Notice of WCDA's Attempt To Remand Coughlin and Revoke Two Probations and Addendum To Post-Trial Motions Stamped With Ex 1 Opt A9 Printed
10 31 13 72675 Motion To Strike Sentencing and Remand Etc Plus Voxox Proof of Service Fax On WCDA Z Young and Stege 65630 63341 71437 72675 and Wastts in 599 607
10 31 13 72675 65630 63341 71437 607 599 Filing and Voxox Fax Proof With 4 4 13 Fax Header's Motion To Strike Remand and Sentencing Memor and Extension of Time Sought Appt of Counsel Etc. Vacate Epo